QUARTER 1 OF 2021 - Economic Laws ...
←
→
Page content transcription
If your browser does not render page correctly, please read the page content below
QUARTER 1 OF 2021
INDIA: COMPETITION LAW UPDATE 2021
SNAPSHOT
Gmail users not coerced to use Gmeet, CCI closes
case against Google
The CCI notes that adding functionality to a product, or app, 04
does not constitute leveraging. Dismisses complaint filed
against Google
CCI to inves�gate WhatsApp’s privacy policy
CCI ordered investigation into WhatsApp’s updated privacy
policy, noting that its investigative powers allow it to 04
intervene even in respect of acts about to be committed in
contravention of Sections 3, 4 and 6 of the Act.
Interim relief granted against MMT and OYO
CCI uses powers under Section 33 of the Act, orders MMT 06
and OYO to re-list delisted companies, Fab Hotels and
Treebo, on their sites.
U�arakhand Agricultural Produce Marke�ng Board
guilty of abuse of dominance, fined INR 1 crore
The CCI finds UAPMB to have limited / restricted the 07
wholesale procurement and distribution of IMFL in the
State of Uttarakhand leading to denial of market access to
producers of certain brands of IMFL.
CCI goes regional
For the first time since inception, the CCI has opened a 09
regional office, in Chennai, for greater reach and flexibility.
SECTORS COVERED IN THIS ISSUE
Informa�on
Logis�cs Retail Insurance Avia�on Hospitality Beverages
Technology
01 © Economic Laws Prac�ce 2021
INDIA: COMPETITION LAW UPDATE 2021
Mergers and Acquisi�ons
CCI approves combina�on between Flipkart in India. The CCI was of the prima facie view that the
and Aditya Birla exclusive arrangement between the Par�es may lead to
preferen�al treatment of Aditya Birla’s products on
On January 20, 2021 the Compe��on Commission of Walmart’s pla�orms in India. This may affect
India (CCI) approved the proposed acquisi�on by Flipkart intra-pla�orm compe��on between brands or sellers
Investments Private Limited (Flipkart) of a minority stake and result in the market outcome being influenced or
of 7.8%, on a fully diluted basis, in Aditya Birla Fashion determined by the pla�orm instead of resul�ng from
and Retail Limited (Aditya Birla) (collec�vely, Par�es). compe��on on merits.
The relevant market proposed by the Par�es was the Based on this observa�on, the CCI issued an advisory to
broad market for B2B sales in India (Broad Relevant the Par�es to not indulge in any such conduct which
Market) or the narrower market segment of B2B sale of could amount to leveraging their control over the
apparel, footwear and accessories in India (Narrower e-commerce pla�orms in favour of the iden�fied Aditya
Relevant Segment). The CCI noted that the combined Birla products.
market share of the par�es in the Broad Relevant Market
was 0-5% and Narrower Relevant Segment was 5-10%. The order of the CCI can be accessed here.
The CCI also noted that the presence of other players in
both markets would pose compe��ve constraints on the CCI approves acquisi�on in Ecom Express by
Par�es post transac�on. CDC Group plc. and PG Esmeralda Pte. Limited
The CCI vide two separate orders approved acquisi�ons
As part of the transac�on, the Par�es had entered into a
of 38.41% and an addi�onal 2.78% of the equity share
commercial agreement for distribu�on of certain Aditya
capital in Ecom Express Private Limited (Ecom), a
Birla products through Walmart’s ecommerce pla�orms
company engaged in the business of providing third
to the exclusion of certain other pla�orms. The CCI
party logis�cs services in India, by PG Esmeralda Pte.
observed that the Walmart Group operates prominent
Limited (PG) and CDC Group plc. (CDC) (collec�vely
e-commerce pla�orms like Flipkart, Myntra and Jabong
Acquirers), respec�vely.
© Economic Laws Prac�ce 2021 02
INDIA: COMPETITION LAW UPDATE 2021
Post the acquisi�on, PG would have representa�on on including its own website myvishal.com. For its
the Board of Ecom and certain other rights in rela�on to opera�ons, it may require third party logis�cs services
ma�ers of Ecom. However, CDC already has a from Ecom. However, given that neither the revenue of
representa�on on the Board of Ecom and has certain Airplaza from its e-commerce ac�vi�es on myvishal.com
addi�onal rights, and would not be acquiring any website nor the market share of Airplaza in e-commerce
addi�onal rights through the present acquisi�on. ac�vi�es was significant, the CCI did not find likelihood
of any concerns of market foreclosure. It approved the
As regards the acquisi�on by PG, the CCI observed that combina�on on January 11, 2021.
there may be poten�al ver�cal overlaps as one of the
en��es in which the holding company of PG has an Similarly, with respect to the acquisi�on by CDC, the CCI
interest, may require third party logis�cs services from noted that though some en��es in the por�olio of CDC
Ecom. The CCI noted that Partners Group, to which PG have availed the services of Ecom, the nature and
belongs, has an indirect financial investment in the volume of these interfaces were insignificant. The CCI
en��es that hold Vishal Mega Mart Private Limited further noted that the proposed acquisi�on did not
(VMM). envisage acquisi�on of any addi�onal rights in the
opera�ons or management of Ecom by CDC. The CCI,
It was noted that Airplaza Retail Holdings Private Limited based on the above, did not find any likelihood of
(Airplaza), a subsidiary of VMM, is engaged in the sale of compe��on concerns and approved the transac�on on
products such as food and grocery; apparel and February 10, 2021.
footwear; home appliances; etc. through its
brick-and-mortar store and e-commerce websites The orders of the CCI can be found here and here.
03 © Economic Laws Prac�ce 2021
INDIA: COMPETITION LAW UPDATE 2021
Enforcement Ac�on
CCI closes informa�on against Google for It highlighted how the personalized informa�on of
integra�ng GMeet with Gmail users will be shared with Facebook Inc. (Facebook)
and its subsidiaries.
On January 29, 2021 the CCI dismissed an informa�on
filed against Google LLC and Google India Digital Services While the previous policy of WhatsApp allowed
Pvt. Ltd. (Google) alleging abuse of dominance by them. exis�ng users to choose whether their data would be
It was alleged that by integra�ng Google Meet into shared with Facebook, the 2021 Policy mandated
Gmail, Google had abused/leveraged its dominant acceptance of data sharing if the users wanted to
posi�on in the email and direct messaging market to con�nue using WhatsApp’s services.
enter into the video-conferencing market in
contraven�on of Sec�on 4(2)(e) of the Compe��on Act, WhatsApp contended that the terms and condi�ons of
2002 (Act). the 2021 Policy fall within the purview of the
Informa�on Technology Act, 2000 and data
While defining the markets, the CCI dis�nguished protec�on/privacy laws and since these issues were sub
between email/video conferencing services and direct judice before various courts in India, the CCI should
messaging services. The CCI, in its order, defined the refrain from looking into them.
relevant markets as (i) ‘the market for providing email
services in India’; and (ii) ‘the market for providing WhatsApp also contended that the 2021 Policy had not
specialized video conferencing services in India’. yet been implemented and therefore, taking suo moto
However, the CCI did not find it necessary to determine cognizance of this policy was premature. The CCI
if Google is dominant in any of the above markets. observed that since WhatsApp had already announced
the policy, the conduct had ‘already taken place’. The CCI
On the issue of leveraging, the CCI found that adding placed reliance on Sec�on 33 of the Act which, according
func�onality to a product, or app, does not cons�tute to the CCI, empowers it to intervene even in respect of
leveraging. The CCI appears to have incorporated a future conduct and casts an obliga�on upon the CCI to
‘coercion standard’ whereby it noted that even though ‘prevent’ prac�ces having an adverse effect on
the Meet tab had been incorporated in the Gmail app, compe��on.
Gmail did not ‘coerce’ its users to use Meet exclusively
and they were free to use any compe�ng Dis�nguishing the Vinod Gupta case1 from the present
video-conferencing app. On this basis, the CCI found no ma�er, the CCI noted that WhatsApp in its earlier policy
contraven�on of the Act by Google and closed the case. provided users an op�on to ‘opt-out’ of sharing user
account informa�on with Facebook within 30 days of
The order of the CCI is available here. agreeing to the updated terms of service and privacy
policy. The CCI observed that the ‘take-it-or-leave-it’
CCI ini�ates inves�ga�on into updated policy nature of 2021 Policy required inves�ga�on in view of
and terms of WhatsApp the market posi�on and market power enjoyed by
2
WhatsApp (as noted in the Harshita Chawla case ).
On March 24, 2021 the CCI ordered an inves�ga�on
against WhatsApp Inc. (WhatsApp) based on a finding The CCI further noted that WhatsApp’s conduct of
that WhatsApp through its 2021 Privacy Policy Update sharing of users personalized data with Facebook or its
(2021 Policy), has prima facie contravened the subsidiaries for targeted ads amounted to degrada�on
provisions of Sec�on 4 of the Act. of non-price parameters of compe��on viz. quality,
which results in objec�ve detriment to consumers,
The CCI took suo motu cognizance of the ma�er based without any acceptable jus�fica�on. Further, the CCI
on various news reports regarding the updated 2021 observed that lower data protec�on by a dominant
Policy no�ng that: enterprise could lead to exploita�on of consumers and
1
Shri Vinod Kumar Gupta v. WhatsApp Inc., Case No. 99 of 2016.
2
Harshita Chawla v. WhatsApp Inc., Case No. 15 of 2020.
© Economic Laws Prac�ce 2021 04
INDIA: COMPETITION LAW UPDATE 2021
have an exclusionary effect on compe�tors. The CCI held contracts in India, have not been made by GIC and
that such conduct prima facie amounted to therefore, there was no case for denial of market access
contraven�on of Sec�ons 4(2)(a)(i), 4(2)(c) and 4(2)(e) of under Sec�on 4(2)(c) of the Act.
the Act.
The CCI considered a decision of the Delhi High Court
The order reflects the expansionist nature of CCI’s which dealt with the same impugned conduct of GIC
inves�ga�ve powers as it clearly recognizes the CCI’s brought forward by the ATMA in the present ma�er. The
intervene even in respect of acts which are in CCI noted that GIC had not placed any restric�on on
contraven�on of the provisions of Sec�ons 3, 4 or 6 if insurance companies to offer products to their customers
such acts are about to be committed. The CCI placed and that the allega�on of resale price maintenance under
reliance on the phrase “prevent prac�ces having adverse Sec�on 3(4)(e) against GIC was unmerited.
effect on compe��on” appearing in the preamble to the
ATMA also alleged that GIC directed insurance companies
Act while exercising its jurisdic�on.
to not cover any direct or indirect losses caused by
reasons related to contagious disease like COVID-19 and
The order of the CCI can be accessed here.
this cons�tuted refusal to deal under Sec�on 3(4)(d) of
CCI dismisses informa�on against General the Act. The CCI observed this allega�on was not jus�fied
Insurance since the posi�on pre and post COVID-19 pandemic
remained unchanged as far as the exclusion of contagious
On January 27, 2021 the CCI dismissed informa�on filed diseases was concerned. It further observed that the
by Automo�ve Tyres Manufacturers Associa�on (ATMA) exclusion of any direct or indirect loss by infec�ous or
against General Insurance Corpora�on of India (GIC) for contagious disease existed even prior to the onset of the
alleged viola�on of Sec�ons 3 and 4 of the Act. COVID 19 pandemic. The CCI also observed that the
The CCI delineated the relevant market as the ‘market for Contagious Disease Endorsement was neither a direc�on
provision of reinsurance services in India’. It observed that nor a mandate to the insurance companies and that they
based on the informa�on on record it appeared that GIC were en�rely free to offer any kind of insurance to the
was the dominant enterprise in the relevant market. The policy holders.
CCI noted that ATMA had alleged a contraven�on of Finally, the CCI noted that ATMA had not substan�ated its
Sec�on 4(2)(a)(ii) of the Act on account of ‘excessive allega�on of viola�on of Sec�on 3(3) of the Act and that
pricing’ without providing any basis. Placing reliance on a there was no evidence to show that GIC was used as a
previously decided ma�er 3 having similar allega�ons, the pla�orm to exchange sensi�ve informa�on or that GIC is
CCI observed that se�ng of premium rates for otherwise facilita�ng any price fixing among the insurance
reinsurance polices could be based on many factors and companies. Based over the aforemen�oned observa�ons,
without proper evidence, the allega�onswere the CCI dismissed the allega�ons against GIC.
unsubstan�ated.
The order of the CCI can be accessed here.
The CCI noted that the regula�ons on account of which
GIC has the right of first refusal over all reinsurance
3
Indian Chemical Council v. General Insurance Corpora�on of India, Case No. 12 of 2019.
05 © Economic Laws Prac�ce 2021
INDIA: COMPETITION LAW UPDATE 2021
CCI finds no case of carteliza�on amongst Rubtub Solu�ons Pvt. Ltd. (Treebo) and Casa2 Stays Pvt.
domes�c airlines Ltd. (Fab Hotels) against MakeMyTrip India Pvt. Ltd.
(MMT) and Ibibo Group Private Limited (Go-Ibibo)
On February 22, 2021 the CCI closed a case of alleged (collec�vely referred as MMT-Go) by direc�ng them to
carteliza�on in the domes�c airline industry. The CCI re-list Treebo and Fab Hotels on their online portals.
based on receipt of a le�er from the Lok Sabha
Secretariat had taken suo moto cognizance of the ma�er. The CCI on October 28, 2019 had found MMT-Go to be
The CCI had analyzed the data for the period from April prima facie dominant in the market for online
2012 to March 2014 in respect of five airlines, namely Jet intermediation services for bookings of hotels in India
Airways (including JetLite), Indigo, SpiceJet, GoAir and and to have prima facie contravened the provisions of
Air India. In its analysis, the CCI observed some degree of Sec�on 3 and 4 of the Act. Accordingly, the CCI had
stability in the market shares of the above companies, directed the DG to ini�ate inves�ga�ons into the
similarity in cost structure of the airlines and despite following allega�ons leveled by Treebo and Fab Hotels
different base fares/fuel surcharge, similarity in prices. which inter alia included Denial of Market Access to
On this basis, the CCI had directed the DG to conduct an competitors of OYO; Predatory Pricing via deep
inves�ga�on into the ma�er. discounting and charging below the average room rate
and Imposition of excessive and unfair conditions.
The DG in its ini�al inves�ga�on report a�er examining
the conduct of the airlines in four major routes had The CCI, in its March 9, 2021 order, placed reliance on
concluded that no contraven�on of the provisions of the Supreme Court’s decision in the SAIL case4 to observe
Sec�on 3 of the Act was made out. This was based on that while assessing any ma�er for the purposes of
informa�on on costs of opera�ons, flights operated, and passing interim orders under Sec�on 33 of the Act, the
passengers carried throughout the year on the said following condi�ons must be fulfilled:
routes, the market share and air fare determina�on etc.
The CCI should be sa�sfied that an act in
The CCI ordered a further inves�ga�on direc�ng the DG
contraven�on to the provisions of the Act has been
to look into other factors such as dynamic pricing, role of commi�ed and con�nues to be commi�ed or is about
algorithms in the so�ware used by these airlines and the to be commi�ed. This sa�sfac�on has to be of much
impact of capacity on pricing of �cket. The DG, a�er higher degree than while forma�on of prima facie
finding no evidence of collusion amongst the airlines view under Sec�on 26(1) of the Act.
concluded once again that the par�es had not violated
the provisions of the Act. The CCI should be convinced that it is necessary to
provide the interim relief sought and whether balance
The CCI in its order observed that ‘a parallel conduct is of convenience lies in providing the relief.
actionable under the Act only when the adaptation to
the market conditions is not done independently and is The CCI should be sa�sfied that ‘there is every
attributable to information exchanged between the likelihood that the party to the lis would suffer
irreparable and irretrievable damage, or there is
competitors or through some other collusive conduct,
definite apprehension that it would have adverse
the object of which is to influence the market’. Having
effect on competition in the market’.
found no evidence on record to establish cartel amongst
airlines during the period April 2012 - March 2014, the The CCI noted that the degree of sa�sfac�on for forming
CCI found no reason to differ with the findings recorded a prima facie view under Sec�on 26(1) ‘is a tentative
by the DG and accordingly closed the case. view at that stage’ as opposed to a ‘definite expression
of the satisfaction recorded by the Commission’ required
The order of the CCI can be found here. to qualify the first condi�on for gran�ng an interim relief
under Sec�on 33.
CCI grants interim relief against MMT and OYO
On March 9, 2021 in a rare exercise of its powers under The CCI also noted that it was an admi�ed posi�on that
Sec�on 33 of the Act, the CCI granted interim relief to MMT-Go had delisted Treebo and Fab Hotel from their
4
Compe��on Commission of India v. Steel Authority of India Ltd., (2010) 10 SCC 744.
© Economic Laws Prac�ce 2021 06
INDIA: COMPETITION LAW UPDATE 2021
pla�orms in April and June 2018 respec�vely, following compe��on landscape �pping the markets in favor of
an agreement with Oravel Stays Private Limited (OYO) (a MMT-Go and OYO, causing an irreparable harm to
close compe�tor of Treebo and Fab Hotels) and as such compe��on. It is per�nent to note that the CCI also
the first condi�on required to be met for a relief under noted that in dynamic markets �ming was of essence
Sec�on 33 was sa�sfied. since the harm of compe��on will be irrevocable.
In respect of the second condi�on, the CCI observed that Therefore, in light of the aforemen�oned condi�ons
the determina�on of convenience is compara�ve in being sa�sfied, the CCI held that the ma�er was a fit
nature whereby the inconvenience caused to the case for exercising the power of interim measures and
informant due to non-grant of relief and to the opposite directed MMT-Go to allow Treebo and Fab Hotels to be
party if the interim relief is granted, need to be assessed. listed on its online portals.
The CCI noted that the balance of convenience lay in
favor of Treebo and Fab Hotels since MMT-Go would not The order of the CCI can be accessed here.
be put to much inconvenience even if they had to
provide them access on its online portals.
CCI penalizes U�arakhand Agricultural
The CCI further noted that under the third condi�on of Produce Marke�ng Board for abuse of
ensuring if there is any irreparable harm or definite dominance
apprehension of adverse effect on competition in the On March 30, 2021 the CCI found the U�arakhand
market, if either of the condi�ons are met, it would be Agricultural Produce Marke�ng Board (UAPMB) to have
deemed sa�sfied. The CCI observed that denial of violated Sec�on 4 of the Act and imposed a fine of INR 1
market access need not be complete and absolute in crores. An informa�on was filed by Interna�onal Spirits
nature. It further held that denial of market access in any and Wines Associa�on of India (ISWAI) alleging abuse of
manner, that takes away the freedom of a subs�tute to dominance by UAMPB through arbitrary and
compete effec�vely and on the merits in the relevant discriminatory procurement of liquor from
market, can amount to denial of market access. It also manufacturers, in disregard to the market demands and
noted that the delis�ng of Treebo and Fab Hotels was the Excise Policy. ISWAI had further alleged that UAPMB
not due to any breach of contractual obliga�ons but had failed to comply with the requirement of
rather emanated from an agreement between MMT-Go maintaining minimum stock levels in contraven�on of
and OYO. Given the market power of MMT-Go and OYO the Excise Policy and of imposi�on of unfair and onerous
and the present market condi�ons in the wake of a condi�ons on the liquor manufacturers.
recovering sector, the CCI observed that con�nua�on of
such an exclusionary agreement may change the
07 © Economic Laws Prac�ce 2021
INDIA: COMPETITION LAW UPDATE 2021
Though the CCI passed the prima facie order under Therefore, based on its assessment of the market and
Sec�on 26(1) in 2016, UAPMB moved the High Court of the changes due to the Excise Policy and the Liquor
Delhi in a writ pe��on seeking the order to be set aside Wholesale Order, the CCI held that the unilateral
on the grounds of UAPMB not being an ‘enterprise’ conduct of UAPMB impacted the inter brand
under Sec�on 2(h) of the Act as a result of which, the compe��on of the brands of India made Foreign Liquor
CCI did not have jurisdic�on over it. This jurisdic�onal (IMFL) being sold in the State of U�arakhand.
challenge was ul�mately dismissed by the High Court
and even by the Supreme Court in appeal. The CCI further assessed the conduct of UAPMB and
noted that it did not place any orders for many brands of
The CCI assessed the record in the ma�er and delineated Pernod and USL for many months despite existence of
the relevant market as the (a) market for wholesale retailers’ demand. The CCI held that UAPMB had limited
procurement of branded alcoholic beverages in the State or restricted the wholesale procurement and
of Uttarakhand; (b) market for distribution of branded distribu�on of IMFL resul�ng in denial of market access
alcoholic beverages in the licensed area of Garhwal to producers of certain brands of IMFL in the State of
Mandal Vikas Nigam Ltd. (OP-2) in the State of U�arakhand. This was held to be in viola�on of Sec�on
Uttarakhand; and (c) market for distribution of branded 4(1) read with Sec�on 4(2)(b)(i) and Sec�on 4(2)(c) of
alcoholic beverages in the licensed area of Kumaun the Act.
Mandal Vikas Nigam Ltd (OP-3) in the State of
Uttarakhand. The CCI further observed that the alcoholic The CCI also assessed the terms of the agreement of
beverage manufacturers were en�rely dependent upon UAPMB with Pernod and USL and took note of certain
the opposite par�es for access to retailers and in turn one-sided and unfair obliga�ons. Relying on its earlier
the end-consumers in the State of U�arakhand and that decisions in the Surinder Singh Barmi case 6 and the
they enjoyed 10% market share in their respec�ve Belaire case,7 the CCI observed that it was immaterial
relevant markets owning to the Excise Policy of the State. whether the inclusion of an unfair and one-sided clause
Based on this observa�on and the factors under Sec�on had any an�-compe��ve effect and that the unfairness
19(4) of the Act, the CCI held opposite par�es to be of such clause needs to be assessed as to whether it
dominant in their respec�ve relevant market. could only be imposed by a dominant en�ty. Accordingly,
the CCI held that UAPMB being the dominant enterprise
The CCI assessed the Excise Policy of the State of was in a posi�on to implement the one-sided
U�arakhand and observed that the provisions of the contractual obliga�ons and had contravened the
Liquor Wholesale Order and its impact with respect to provision of Sec�on 4(2)(a)(i) of the Act.
dominant posi�on and/or abuse thereof, could be
scru�nized under the provisions of Sec�on 4 of the Act. While assessing the conduct of OP-2 and OP-3, the CCI
The CCI placed reliance on the decision of the Supreme observed that they had placed indents with UAPMB in
Court in the ma�er of Khoday Distilleries Ltd. and Others accordance to the Excise Policy and the Liquor
v. State of Karnataka and5Others, and noted that while it Wholesale Order, and that they were en�rely dependent
is the preroga�ve of each individual State to manage the upon UAPMB for obtaining supplies and could not
trade of liquor, once the State permits trade or business directly procure from the IMFL manufacturers. The CCI
in liquor, it cannot discriminate between the persons or as such did not deem it fit to hold OP-2 and OP-3 to be
suppliers who are qualified to carry on trade or business. liable and complicit with UAPMB in contraven�on of the
provisions of the Act. The CCI further assessed the
The CCI further assessed the sales data during the financials and the mi�ga�ng factors pleaded by UAPMB
relevant period and observed that the sudden change in and imposed a penalty of an amount of INR 1 crores
sales pa�ern of certain brands of IMFL vis-à-vis others under Sec�on 27(b) of the Act.
was indica�ve of changes induced on the supply or
distribu�on side as opposed to the demand side. The decision of the CCI can be accessed here.
5
(1995) 1 SCC 574.
6
In Re: Surinder Singh Barmi and The Board of Control for Cricket in India, Case No. 61 of 2010.
7
Belaire Owner’s Associa�on v. DLF Limited &Ors., Case No. 19 of 2010.
© Economic Laws Prac�ce 2021 08
INDIA: COMPETITION LAW UPDATE 2021
Policy Update
CCI inaugurates regional offices
On February 26, 2021, the Union Minister for Finance
and Corporate Affairs (MFCA) Smt. Nirmala Sitharaman
virtually inaugurated the first of the CCI’s Regional
Offices in Chennai. The press release indicates that the
Chennai Office of CCI will act as an office to facilitate
enforcement, inves�ga�on, advocacy func�on in
coordina�on with its Delhi office. The press release
further stated that this regional office is likely to cater to
the requirements of Tamil Nadu, Kerala, Karnataka,
Andhra Pradesh, Telangana and the Union Territories
Puducherry and Lakshadweep.
The Chairperson CCI, in his speech at the inaugural
func�on, highlighted that in light of the wide gamut of
the CCI’s ac�vi�es and countrywide spread of
stakeholders, a need of having regional offices of the CCI
was felt. The regional offices will aid in greater reach and
flexibility to the CCI in carrying out its func�ons.
The official press release by the Ministry of Corporate
Affairs can be accessed here and the speech of the
Chairperson, CCI can be accessed here.
We hope you enjoyed reading our Compe��on
Update for this quarter.
We welcome any comments/queries
at insights@elp-in.com or write to our authors:
Ravisekhar Nair – ravisekharnair@elp-in.com
Parthsarathi Jha - parthjha@elp-in.com
Abhay Joshi - abhayjoshi@elp-in.com
Tanaya Sethi – tanayasethi@elp-in.com
Sahil Khanna – sahilkhanna@elp-in.com
Ketki Agrawal-ketkiagrawal@elp-in.com
Animesh Kumar – animeshkumar@elp-in.com
09 © Economic Laws Prac�ce 2021MUMBAI
elplaw.in
9th Floor, Mafatlal Centre
Vidhan Bhavan Marg
Nariman Point, Mumbai 400 021 insights@elp-in.com
T: +91 22 6636 7000
/elplaw.in
NEW DELHI
801 A, 8th Floor, Konnectus Tower, Bhavbhuti Marg
Opp. Ajmeri Gate Railway Station, Nr. Minto Bridge /ELPIndia
New Delhi 110 001
T: +91 11 4152 8400
/company/economic-law-practice
AHMEDABAD
801, 8th Floor, Abhijeet III
Mithakali Six Road, Ellisbridge
Ahmedabad 380 006
T: +91 79 6605 4480/8
PUNE
202, 2nd Floor, Vascon Eco Tower
Baner Pashan Road
Pune 411 045
T: +91 20 4912 7400
BENGALURU
6th Floor, Rockline Centre
54, Richmond Road
Bengaluru 560 025
T: +91 80 4168 5530/1
CHENNAI
No 18, BBC Homes, Flat-7 Block A
South Boag Road
Chennai 600 017
T: +91 44 4210 4863
DISCLAIMER:
The information contained in this document is intended for informational purposes only and does not constitute legal opinion or advice. This document
is not intended to address the circumstances of any particular individual or corporate body. Readers should not act on the information provided herein
without appropriate professional advice after a thorough examination of the facts and circumstances of a particular situation. There can be no
assurance that the judicial/quasi judicial authorities may not take a position contrary to the views mentioned herein.
© Economic Laws Practice 2021You can also read
